5 replies to this topic

[Mohamed Tawfik]

Hi every body

Please tell me your opinions:

There is a factory that produces soft drinks. The factory carry Chlorination of water for killing bacteria then filtrate the water through carbon filter to remove the residues of free chlorine before using this water in preparing soft drinks. Any residue of free chlorine will effect on the quality of the soft drink product and will changing its color, taste and effect on the image of the company

The factory considers the carbon filtration step a CCP and they monitor the residual of free chlorine after the filtration step. (Should be free)

Also the factory consider the step of carbonation (adding Co2 to the syrup to prepare the final product)as a CCP because the CO2 may contains H2S , acetaldehyde and impurities that affect on the taste , color & company image and they inspect the received CO2 for each batch (check COA and measuring purity (should be not less than 99.9% ) and also take samples daily to check purity (99.9%) Also they change filter of the on line CO2 purifier (Dominick Hunter Type) every 6 months

My opinion for both of the above points that there no severs hazards and we can consider them as OPRPs and not CCPs. Also they affect on quality more that the Food safety So we can’t consider them CCPs. Because a little of chlorine, H2S or acetaldehyde in the soft drink bottle will not affect of the health of the consumer and he will reject the product for the first taste

The reply of the company QA that the changing in color & taste will has very bad effect on company image and violate the food laws and legislation So he have consider them CCPs

Please tell me your opinions.

[Modarres]

Hi every body

Please tell me your opinions:

There is a factory that produces soft drinks. The factory carry Chlorination of water for killing bacteria then filtrate the water through carbon filter to remove the residues of free chlorine before using this water in preparing soft drinks. Any residue of free chlorine will effect on the quality of the soft drink product and will changing its color, taste and effect on the image of the company

The factory considers the carbon filtration step a CCP and they monitor the residual of free chlorine after the filtration step. (Should be free)

Also the factory consider the step of carbonation (adding Co2 to the syrup to prepare the final product)as a CCP because the CO2 may contains H2S , acetaldehyde and impurities that affect on the taste , color & company image and they inspect the received CO2 for each batch (check COA and measuring purity (should be not less than 99.9% ) and also take samples daily to check purity (99.9%) Also they change filter of the on line CO2 purifier (Dominick Hunter Type) every 6 months

My opinion for both of the above points that there no severs hazards and we can consider them as OPRPs and not CCPs. Also they affect on quality more that the Food safety So we can’t consider them CCPs. Because a little of chlorine, H2S or acetaldehyde in the soft drink bottle will not affect of the health of the consumer and he will reject the product for the first taste

The reply of the company QA that the changing in color & taste will has very bad effect on company image and violate the food laws and legislation So he have consider them CCPs

Please tell me your opinions.

Hi!

I think u want change from HACCP approach to ISO 22000...., ok, we have to obey of 22000 requirements, so we can't simply decide about of CCP or OPRP on base of just our criteria e.g. critical or not, rather we should first analysis our step's FS hazards, then select a combination of control measures (via current control measures, current PRPs, definition new control measure....) then (this is deference between HACCP & 22000:) decide about of Management Strategy for managing of every control measure base on seven criteria that mentioned in 7.4.4 clause. These strategies are:managing control measures as PRP, OPRP or CCP. Let me give u an example:

Microbiological contamination in syrup (water+sugar) from water, sugar or tank and pipes maybe in Soft Drink line is very likely and have high adverse effects on health, so we need to some control measures such as:

• water treatment,
• CIP of syrup tank and pipes,
• syrup pasteurization

Now (we assume these three control measures have been validated - 8.2 clause) we assess every one versus 7.4.4.a to g criteria. Resulting every categorizing method should be based on this: "more effective, monitor-able, FS hazard severity control ability cause a control measure to be belonged to HACCP Plan"; so maybe after control measures assessment, water treatment and CIP go to OPRP (clause 7.5) and syrup pasteurization goes to HACCP plan (clause 7.6).

[Charles.C]

Dear Mohamed Tawfik,

I assume you are currently basing your Food Safety System on ISO 22000 since you refer to OPRPs.

Your company appears to have some confusion over the “use” of hazard analysis in ISO 22000. I hope this brief overview (refer ISO 22000, section 7.4) helps –

1. Identify your organization’s food safety hazards.
2. Determine where each hazard may be introduced.
3. Specify acceptable hazard levels for each hazard.
4. Assess each hazard and decide if you are required to control it (eg see ISO 22000 / 22004, para 7.4.3)
5. If step 4. concludes that control is required, select control measures (CMs) to control your hazards (eg see ISO 22000 / 22004, para.7.4.4)
6. validate the effectiveness of the CMs (eg see ISO 22000 / 22004, paras 7.4.4, 8.2)
7. Categorise the CMs into OPRPs or HACCP Plan/CCPs (eg see ISO 22000 / 22004, para 7.4.4)

Accordingly –

(a) hazards which are non-safety related are not relevant to ISO 22000.
(b) severity of the hazard is not the only factor determining if control is necessary, an appropriate risk assessment is required. (eg see step 4 above)
© The decision as to whether a CM(s) is associated with an OPRP progam or a HACCP Plan/CCP is as per step 7 above.

If your organisation wishes to include Quality (ie non-safety) factors in an auditable Standard, SQF 2000 offers one route. (Details of this Standard are freely downloadable from the net).

Rgds / Charles.C

[Mohamed Tawfik]

Thanks a lot dears for your professional replies

I found on the forum two attached files made by a member on the forum . These two files are giving examples about Hazard analysis and assessment of control measures according the ISO 22000 point of view

The first is: Methodology for Determination of Hazard Control Measures, CCP’s and OPRP’s.

The second is : an example for the implementation of the Assessment of Control Measures according the above methodology and based on seven criteria that mentioned in (ISO 22000 clause 7.4.4 )

I think the hazard analysis is good but there is a mistake in methodology of the Assessment of Control Measure (ISO 22000 clause 7.4.4 ) specially related to rating value for OPRPS & CCPs. I think OPRPS supposed to be < 14 and HACCP >14 and not vice versa

I attached the two files for you and I will be highly appreciate if you read these files and tell me your opinions to avoid confusion for me and any other members

assessment of Control Measures

Management

Selected Combination of Control Measures

Assessment Criteria

(Levels of effectiveness)

Total

1: Low / 2: Medium / 3:High

HACCP Plan

OPRP

a

b

c

d

e

f

g

< 14

>14

1

1

1

1

1

1

1

7

3

3

3

3

3

3

3

21

Kind regards

Mohamed Tawfik

Attached Files

•  Methodology_for_determination_of_Hazard_Controls__CCP__s_and_oPRP__s.doc   77KB   242 downloads
•  CCP___oPRP_list.xls   244KB   258 downloads

[Charles.C]

Dear Mohamed Tawfik,

Yes, the document is attributed to Bennii. Yr observation was also noticed by other people and is discussed in the link below. Bennii also posted a second version later in the thread to revise / clarify her initial document (although one element [ penultimate] in her new list seemed questionable to myself.)

http://www.ifsqn.com...dpost__p__19765

I should state that I am not a user of ISO 22000 myself so my theoretical / practical comments are primarily a deduction from published works / other posts on this forum. People who have to directly experience audits should provide the best practical data.

ISO 22004 implies that it is not mandatory to include all of (a-g) within the categorisation process and mentions a “guide” of 3 criteria.

ISO 22004 states that “the organisation may focus on having as many of the control measures as possible managed by operational PRPs and only a few managed by the HACCP plan, or the opposite." The meaning of “focus” is obviously subjective.

ISO 22000 states that "the organisation shall validate that “the CMs are effective and capable of, in combination, ensuring control of the identified food safety hazard(s) to obtain end products that meet the defined acceptable levels" (My underline). It is unfortunate that many published documents do not initially state / justify the acceptable levels of relevant FS parameters.

Pragmatically, to give a general answer to yr post, comments in this forum suggest that most auditors will accept any of the varying presentations provided in above link if, as is I think possible, you can justify them within the context of 22000/ 22004, para 7.4.4 ( and linked paras).(Frequent use of the words "interpretation", "subjective" is maybe recommended )

More specifically, Charlorne’s format (perhaps requiring a little text smoothing) is surely the quickest, Bennii’s (revised) contains more information and more work (subjective questions require thought ). Note that neither of these documents mentions “acceptable levels”. The ease of audit acceptance may also depend on yr final result, eg if there are no CCPs, some auditors start to worry.
Decision Trees also exist (some from a contributor to the original ISO 22000 team), eg see the Procert tree in this link compilation. (This can be seen to be following yet another logic variation) -

http://www.ifsqn.com...oprp-selection/

Rgds / Charles.C

[Mohamed Tawfik]

Thanks Modarres & Thnaks Charles.C for clarification
I hope in the future new publications relating this subject will be issued
regards
Mohamed Tawfik